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Advertisements in which AI-generated virtual figures (virtual doctors, experts, etc.)—often indistinguishable from real people—endorse products are spreading rapidly across social media. Effective June 1, 2026, an amendment to the Korea Fair Trade Commission's Review Guidelines on Recommendations and Endorsements in Display and Advertising introduced a new duty: such ads must disclose that "this figure is an AI-generated virtual persona." Omitting this disclosure may constitute unfair advertising under the Act on Fair Labeling and Advertising (Display and Advertising Act). This post explains the new disclosure duty and what advertisers must prepare.

[Table of Contents]

1. Why AI virtual-model ads raise concern

2. Virtual personas added as the fifth 'endorsement subject'

3. What penalties apply if disclosure is omitted

4. How this differs from the AI Framework Act's disclosure duty

5. What advertisers should check now

1. Why AI virtual-model ads raise concern

Recently, virtual doctors and experts—hard to tell apart from real people—have appeared in social media ads recommending or endorsing product effects. The core issue is that the virtual figure does not actually exist. Consumers tend to treat the on-screen figure as advice from a genuine expert or a real consumer review, which directly affects purchasing decisions.

The Korea Fair Trade Commission viewed this as creating a risk of misleading consumers into mistaking virtual personas for real people's reviews, and amended the guidelines so that such advertising is no longer a regulatory blind spot.

2. Virtual personas added as the fifth 'endorsement subject'

The existing endorsement review guidelines regulated four endorsement subjects: (1) consumers, (2) celebrities, (3) experts, and (4) organizations. The key change is the addition of a fifth subject—(5) virtual personas.

In other words, when an AI-generated virtual figure recommends or endorses a product, the advertiser must disclose to consumers that "this figure is an AI-generated virtual persona." This is not a mere recommendation but a mandatory disclosure duty imposed on the advertiser.

3. What penalties apply if disclosure is omitted

If an ad is made to look like a review from a real expert or consumer without disclosing that the figure is virtual, it may be assessed as advertising that misleads consumers. In that case it may amount to unfair advertising under the Display and Advertising Act (deceptive labeling or advertising) and become subject to corrective orders, surcharges, and other sanctions.

Because the endorsement review guidelines serve as a concrete standard for judging unfair advertising under the Display and Advertising Act, a violation of the guidelines' disclosure duty leads directly to potential liability under the Act.

4. How this differs from the AI Framework Act's disclosure duty

Disclosure of AI-generated content is also addressed by the AI Framework Act (인공지능기본법). That Act tends to govern general disclosure of generative-AI outputs as a whole. By contrast, this endorsement-guideline amendment governs the specific context of advertising—particularly virtual personas endorsing products—under the Display and Advertising Act, so the scope of application differs.

Therefore, advertisers using AI virtual personas as ad models should separately check both the disclosure duty under the AI Framework Act and the disclosure duty under the Display and Advertising Act and the endorsement review guidelines.

5. What advertisers should check now

If you already use, or plan to use, AI virtual personas in advertising, you should first review the following.

1. Whether the ad's visuals and copy clearly let consumers recognize the figure as an "AI-generated virtual persona"

2. Whether, if the virtual figure poses as an expert (e.g., a doctor), it endorses product effects without an actual qualification or basis

3. Whether guidelines are in place so the disclosure duty is not omitted in ads run through influencers or agencies

The specific method of disclosure (where and how to display it) may vary by the form of each ad, so it is safest to obtain legal review before running the campaign.

AI Advertising and Display Law Counsel: Cheongchul Law Firm

Drawing on practical experience in antitrust and display-advertising law as well as AI and emerging-business matters, Cheongchul Law Firm helps assess the legality of marketing that uses AI virtual personas and generative AI, and supports responses to risks under the Display and Advertising Act. If you have concerns about AI advertising disclosure duties or unfair-advertising sanctions, please consult with a Cheongchul attorney.

This post is provided for general legal information and does not constitute legal advice on any specific matter. Outcomes may differ depending on the facts of each case, so please consult an attorney.